Raynera vs.

Hiceta
G.R. No. 120027 | April 21, 1999
FACTS:
1. Petitioner Edna Raynera was the widow of Reynaldo Raynera and
the mother and legal guardian of the minors Rianna and Reianne
2. Respondents Freddie Hiceta and Jimmy Orpilla were the owner and
driver, respectively, of an Isuzu truck-trailer, involved in the
accident.
3. March 23, 1989, at about 2am:
- Reynaldo Raynera was on his way home. He was riding a
motorcycle traveling on the southbound lane of East Service
Road, Cupang, Muntinlupa.
- The Isuzu truck was travelling ahead of him at 20 to 30
kilometers per hour. The truck was loaded with two (2) metal
sheets extended on both sides, two (2) feet on the left and three
(3) feet on the right. There were two (2) pairs of red lights, about
35 watts each, on both sides of the metal plates.
- The asphalt road was not well lighted.
- At some point on the road, Reynaldo Raynera crashed his
motorcycle into the left rear portion of the trucktrailer, which
was without tail lights.
- Due to the collision, Reynaldo sustained head injuries and truck
helper Geraldino D. Lucelo rushed him to the Paraaque Medical
Center.
- Upon arrival at the hospital, the attending physician, Dr. Marivic
Aguirre, pronounced Reynaldo Raynera dead on arrival.
4. At the time of his death, Reynaldo was the manager of the
Engineering Department, Kawasaki Motors (Phils.) Corporation; 32
y/o; had a life expectancy of 65 y/o; annual net earnings of not less
than P73,500
5. Heirs of deceased demanded from respondents payment of damages
arising from the death of Reynaldo Raynera as a result of the
vehicular accident
6. Respondents refused to pay the claims
7. Petitioners filed with RTC Manila a complaint for damages against
respondents owner and driver of Isuzu truck
- Sought recovery of damages for the death of Raynera caused by
the negligent operation of the truck-trailer at nighttime on the
highway, without tail lights
8. Respondents:

9.

10.
11.
12.

Truck was travelling slowly on the service road, not parked

improperly at a dark portion of the road, with no tail lights,
license plate and early warning device
TC: in favor of petitioners; found respondents negligent because the
truck had no license plate and tail lights; there were only 2 pairs of
red lights, 50 watts each, on both sides of the steel plates; the truck
was improperly parked in a dark area; the respondents negligence
was the immediate and proximate cause of Rayneras death; reduced
responsibility of respondents by 20% on account of victims own
negligence
Respondents appealed to CA
CA: Rayneras bumping into the left rear portion of the truck was the
proximate cause of his death, and consequently, absolved
respondents from liability
Hence, this petition for review on certiorari

ISSUE: Whether or not respondents were negligent; If so, whether such

negligence was the proximate cause of the death of Reynaldo Raynera
HELD: NO
RATIO:
Negligence is the omission to do something which a reasonable man, guided
by those considerations which ordinarily regulate the conduct of human
affairs, would do, or the doing of something, which a prudent and reasonable
man would not do.
Proximate cause is that cause, which, in natural and continuous sequence,
unbroken by any efficient intervening cause, produces the injury, and without
which the result would not have occurred.
During the trial, it was established that the truck had no tail lights. The
photographs taken of the scene of the accident showed that there were no tail
lights or license plates installed on the Isuzu truck. Instead, what were
installed were two (2) pairs of lights on top of the steel plates, and one (1)
pair of lights in front of the truck. With regard to the rear of the truck, the
photos taken and the sketch in the spot report proved that there were no tail
lights.
Despite the absence of tail lights and license plate, respondents truck was
visible in the highway. It was traveling at a moderate speed, approximately
20 to 30 kilometers per hour. It used the service road, instead of the highway,

because the cargo they were hauling posed a danger to passing motorists. In
compliance with the Land Transportation Traffic Code (Republic Act No.
4136), respondents installed 2 pairs of lights on top of the steel plates, as the
vehicles cargo load extended beyond the bed or body thereof.
We find that the direct cause of the accident was the negligence of the
victim. Traveling behind the truck, he had the responsibility of avoiding
bumping the vehicle in front of him. He was in control of the situation. His
motorcycle was equipped with headlights to enable him to see what was in
front of him. He was traversing the service road where the prescribed speed
limit was less than that in the highway.
Traffic investigator Cpl. Virgilio del Monte testified that two pairs of 50watts
bulbs were on top of the steel plates, which were visible from a distance of

100 meters. Virgilio Santos admitted that from the tricycle where he was on
board, he saw the truck and its cargo of iron plates from a distance of ten (10)
meters. In light of these circumstances, an accident could have been easily
avoided, unless the victim had been driving too fast and did not exercise due
care and prudence demanded of him under the circumstances.
It has been said that drivers of vehicles who bump the rear of another
vehicle are presumed to be the cause of the accident, unless contradicted
by other evidence. The rationale behind the presumption is that the driver of
the rear vehicle has full control of the situation as he is in a position to
observe the vehicle in front of him.